Environmental Cleanup at Navy Facilities Risk-Based Methods (1999) / Chapter Skim
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1 Introduction
1 Introduction
Pages 15-34
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From page 15... ...
The main impetus for remediation of waste sites has been the enactment of federal hazardous waste statutes in the late 1970s and early 1980s. The two most noteworthy, the Resource Conservation and Recovery Act (RCRA)
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Of the 4,448 sites, 1,966 sites were in a study phase, 629 sites were being remediated, and 1,853 sites were considered to require no further action. During FY97, the Navy spent a total of $549 million on environmental cleanup activities at its sites.
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, alternative policies are being developed for site cleanup. Remediation policy is shifting toward increased use of risk-based decisions to establish cleanup goals and reduce the iOver 80 percent of all sites evaluated with the Navy's Relative Risk Site Evaluation model involve ground water contamination.
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This report evaluates the use of risk-based methodologies for closing waste sites at Navy facilities, recognizing that this approach could result in site management strategies that eventually cause unanticipated harm to human health and the environment.2 The introductory chapter of this report provides a brief overview of the current regulatory framework for environmental remediation, the characteristics of the contamination at Navy sites, and the pressing cleanup challenges facing the Navy. The report reviews and critiques risk-based approaches including EPA policies, American Society for Testing and Materials (ASTM)
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Depending on the amount of contamination and the type of affected media, cleanup activities at individual hazardous waste sites can range from several thousand dollars to tens of millions of dollars for the more recalcitrant contaminants in unfavorable hydrogeologic settings. During the 1980s, these fiscal limitations received considerable atten
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The goal of resource conservation is to return sites to unrestricted uses. Other cleanup goals, such as technology-based goals or risk-based goals, may result in more restricted uses of the land following such remedial activities as partial cleanup and containment.
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The state UST programs and the petroleum industry, therefore, had similar interests in developing risk-based approaches for petroleum hydrocarbon contamination, and much of the technical input to the ASTM RBCA standard guide came from these orga At the present time, many states have formally adopted a risk-based approach for managing soil and ground water contaminated with petroleum hydrocarbons. As discussed in Chapter 2, there is a trend toward adopting a risk-based approach for other environmental contaminants (such as chlorinated solvents, industrial chemicals, pesticides, and metals)
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Thus, unlike at other non-NPL facilities, the EPA has regulatory authority at non-NPL BRAC facilities, along with state environmental regulators. It is evident from the above that the Navy operates its Environmental Restoration Program in a complex regulatory environment.
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Current EPA guidance requires that a human health risk assessment and an ecological risk assessment be conducted, which, at the majority of sites, involves a quantitative assessment. Information from the remedial investigation is used to conduct a feasibility study (FS)
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. 4Site closeout implies that the DOD has completed active management and monitoring at an environmental restoration site, and no additional environmental restoration funds are expected to be expended at the site, unless the need for additional remedial action is demonstrated.
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This refers specifically to the priority-setting process "Relative Risk Site Evaluation Framework" (Anderson and Bowes, 1997) that allocates funding in the Environmental Restoration Program.
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Their enormous size underscores the amount of material that may be released if a tank were to leak. It also highlights the size and scope of the Navy's environmental cleanup program.
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These data represent all hazardous waste sites in the United States and its territories, as reported by the Navy. Organic contaminants are the most common contaminants found at Navy facilities.
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The wide variety of contaminants, the unique hydrogeologic conditions, and the many regulatory authorities present at North Island demonstrate the highly variable environment in which cleanup takes place. PRESSING CLEANUP CHALLENGES Cleanup Cost Like other responsible parties, the Navy is faced with environmental cleanup responsibilities that take time, resources, and attention away from its principal mission.
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This distribution of costs among Navy sites, which was expected and is appropriate, suggests that management and response at high risk sites is critical for controlling overall cleanup costs. The Navy has not completed an analysis of how cost estimates might vary if alternative remediation strategies for high risk sites were employed.
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, which facilitate the consideration of diverse local concerns at bases undergoing cleanup. In general, these efforts have made cleanup operations more consistent across regions.
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Because contamination has occurred across this broad spectrum of environmental compartments, the need for and complexity of ecological risk assessments is great. Such ecological risk assessments must give consideration to a wide range of transport mechanisms and biological receptors.
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. However, almost all naval facilities are also significantly contaminated with other organic contaminants, such as chlorinated solvents, heavy metals, and pesticides, that have different mobility and extremely long environmental half-lives in terrestrial, aquatic, and marine media (Department of the Navy, 1998~.
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From page 33... ...
These factors, combined with the recent popularity of the ASTM Risk-Based Corrective Action standard guide for Petroleum Release Sites, have led the Navy to consider implementing a new risk-based methodology for cleanup of all their hazardous waste sites. As this report will demonstrate, risk-based methodologies have strengths and weaknesses that restrict their implementation at complex sites.
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From page 34... ...
Management Guidance for the Defense Environmental Restoration Program, Washington, D.C. Russell, M., E
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